Policy & Press

IMHSA’s response to the proposals contained in Liberating the NHS: Greater Choice and Control

About IMHSA The Independent Mental Health Services Alliance (IMHSA) is a group of nine leading independent providers of mental health services, including Ansel Group, Care UK, Castlebeck, Craegmoor, Cygnet, Partnerships in Care, Pastoral Care, St Andrews Healthcare and The Retreat at York. Collectively, we run more than 500 settings across the country delivering a wide range of high-quality services to adults with mental health problems. Our aim is to improve outcomes for people with mental health needs. We plan to meet this aim by constructively informing central and local government policy that relates to our work, through positive dialogue with policymakers. We also work collectively as a sector in understanding developments in government policy and in discovering how our services might adapt to meet the requirements of policy changes. Summary of response:

The choice agenda should cover almost every aspect of patient care, and should be assumed not granted.

There should be an agreed explanation of what choice means for a patient.

Choice should be extended to mental health services, based on outcomes, safety, locality and value. Choices made before the patient‟s arrival on a mental health ward should also be supported.

Any willing provider should be introduced within mental health services, counselling services and services for those with long-term conditions as a priority.

This is a new area for mental health and there will be significant challenges throughout its implementation.

There should be a list of pre-approved providers to extend choice to unplanned care and an “any willing provider” directory for commissioners and providers.

Patients should have access to the right information to be able to make decisions, and supported by an independent advocacy service with the ability to appeal to a relevant regulator.

The main challenge is the absence of joint commissioning and separate budgets. The main risk is if the agenda is not supported by significantly robust political will.

Responses to questions Q1. How should people have greater choice and control over their care? How can we make this as personalised as possible?

1.1 Choice for all patients over almost any aspect of their care should be assumed rather than given. The choice agenda should not simply be reduced to a matter of controlling a budget and should apply even then the patient does not hold the budget.

1.2 It should include choice in more mundane issues such as food choices or the gender of a care worker.

1.3 An explanation of what choice means for a patient should be agreed between patients, providers and commissioners.

1.3 An explanation of what choice means for a patient should be agreed between patients, providers and commissioners.

Q2. Which healthcare services should be our priorities for introducing choice of any willing provider?

2.1 Introducing choice of any willing provider within mental health services, counselling service and services for people with long-term conditions should be prioritised. This includes IAPT, CMH services and day services.

Q3. How can we offer greater choice of provider in unplanned care?

3.1 There should be a list of pre-approved providers in order to offer greater choice in unplanned care.

Q4. What would help more people to have more choice over where they are referred?

4.1 Choice should be provided at the initial GP consultation stage and via self-referral.

4.2 Patients should have access to information that allows them to make consistent and like for like comparisons between service providers. They could also be supported by independent advocacy services.

Q6. Are these the right choices for users of mental health services, and if not why not?

6.1 These are the right choices for users of mental health services, but they must include access for any willing provider to deliver these services. The right choices must be based on outcomes, safety, locality and value.

6.2 Many choices are made before a patient‟s arrival on a mental health ward and these intermediate choices should also be supported.

6.3 For some patients, it is more appropriate that the choice be exercised via their carer or advocate.

Q18. How do we make sure that everyone can have a say in their healthcare

18.1 Carers and patients voices should be supported throughout the decision making process. There should be support from providers and carers with the service user as the lead in discussions.

Q23. Should healthcare professionals support the choices their patients make, even if they disagree with them?

23.1.1 Healthcare professionals should support the choices their patients make even if they disagree, but this must be subject to an assessment of competence, safety and ultimately legal guidance.

Q36. How should people be told about relevant research and how should their preferences be recorded?

36.1 There should be an obligation on providers to share information. Providers should be required to share information with patients as part of the contractual relationship between commissioners and providers.

Q41. Do you agree with proposed approach to establishing a provider’s fitness to provide NHS services? What other criteria would you suggest?

41.1 Another criterion should be registration by the Care Quality Commission.

Q43. Do you agree that an “any willing provider” directory should be established to make it easier for commissioners to identify providers that are licensed and have agreed to the NHS standard contract terms and conditions? 43.1 An “any willing provider” directory should be established, and it should be accessible to service users as well. Q46. What do you consider to be the main challenges to ensuring that people receive joined-up services, whatever choices they make, and how should we tackle these challenges?

46.1 The main challenge is an absence of joint commissioning and separate budgets funding one individuals care. This should be resolved by a more consistent approach to case management and a clear definition of outcomes.

Q53. If you do not get a choice you are entitled to, what should you be able to do about it?

53.1 If you do not get the choice you are entitled to, you should be able to appeal to Monitor or another relevant regulator that has the power to investigate the issue and ensure compliance.

Q54. What do you think are the main risks associated with choice and how should we best mitigate these risks?

54.1 The main risk is that if the agenda is not supported by significantly robust political will, it may falter. This is a new area, particularly for mental health and there will be significant challenges throughout its implementation. Expectations of what this agenda will deliver in reality must be closely managed.

54.2 Other risks include the limiting of information to influence choice and the devolution of budgets and responsibilities to provider arms.

Recommendations:

Choice for all patients should be assumed over almost every aspect of their care, including more mundane issues.

An explanation of what choice means for a patient should be agreed between patients, providers and commissioners.

Choice of any willing provider should be prioritised within mental health services, counselling services and services for people with long-term conditions.

People should have access to information that allows them to make decisions and should be supported by an independent advocacy services.

Access to any willing provider should be extended to mental health services.

An „any willing provider‟ directory should be established, and accessible to service users as well.

If individuals do not get a choice they are entitled to they should be able to appeal to Monitor or another relevant regulator.

Healthcare professionals should support patient choices even if they disagree with them, but this should be subject to an assessment of competence and legal guidance,